A GUIDE FOR EXPORTERS OF USED GOODS 2516 2009 IMPORTANT INFORMATION This brochure contains important information from the EUCorrespondents’ Guidelines No. 1, Competent Authorities and other relevant sources. Used goods from industrialised countries have become increasingly sought-after commodities in some developing countries. This has also led to a massive flow of obsolete electrical and electronic equipment (e-waste) to some developing countries. Some of this equipment contains hazardous substances that can have serious consequences on the environment and human health - especially when they end up as waste and/or are improperly managed. Shipments of these items are therefore strictly regulated in Norway and within the European Union (EU). So before you export such goods, please note that: • your shipment may be classified as «waste» and therefore treated as an illegal waste shipment by waste regulation authorities or customs. Only good quality used goods that do not contain substances prohibited by law, can be legally exported from Norway and the EU to developing countries. It is not always easy to distinguish between used goods and waste. This guidance brochure attempts to bridge this information gap by highlighting some of the dos and don’ts of shipment of used goods. This will help exporters to differentiate between high and poor quality used goods. This brochure is meant for all those involved in the export of «used goods» – private persons, companies, organisations and carriers. WASTE OR «USED GOODS»? The central question is – «when is a used item classified as waste?» To make this decision it is necessary to examine the life history of an item on a case by case basis. In addition, there are a number of important considerations mentioned in this brochure that need to be taken into account. WHAT IS WASTE? According to section 27 of the Norwegian Pollution Control Act, the term «waste» means discarded objects of personal property or substances. Surpluses from service industries, manufacturing industries and treatment plants, etc. are also considered as waste. 2 WHAT IS ILLEGAL WASTE SHIPMENT? It is generally prohibited under the Norwegian Waste Regulation to export waste to developing countries. But there are some exceptions under certain conditions. Please, contact the Norwegian Pollution Control Authority (SFT) for more information. The EU’s Regulation (EC) No 1013/2006 on shipment of waste, which is implemented in Norway (see chapter 13 of the Norwegian Waste Regulation), has set out legal requirements and measures to facilitate the prevention and detection of illegal waste shipments. As a result, customs and other law enforcement officers in some European countries have recently stopped several shipments of used goods from leaving Europe. The contents were considered as waste and therefore illegal waste shipment in accordance with Reg. (EC) No 1013/2006. As a rule, if a shipment is regarded as illegal by a transit country in Europe and sent back to Norway, the cost arising from the return of the consignment, including transport, storage and recovery or disposal, shall be charged to the exporter pursuant to chapter 13 of the Norwegian Waste Regulation. The same rule applies to containers or vehicles detained or stopped in Norway. - So make sure that you are shipping «used goods» and not «waste». IN ORDER TO SHIP USED GOODS FROM NORWAY IN A LEGAL WAY, PLEASE CHECK THE LIST BELOW: • The item must be in functional order (i.e. the item must be evaluated and fully tested) • The item is highly marketable • The item does not contain a substance that is prohibited by law • The age of the item is reasonable (relatively new technology) • The outward /external appearance of the item does not show any waste characteristics • The packaging/packing is sufficient for protection during transport, loading and unloading • Copies of receipts or contracts relating to the sale and/or transfer of ownership can be provided 3 ITEMS THAT SHOULD NOT BE EXPORTED PICTORIAL EXAMPLES OF SOME GENERAL CHARACTERISTICS OF WASTE If the used item(s) being exported shows any of the characteristics below, the shipment will be regarded as an illegal shipment. A used item will be considered as waste if: • It is not complete – essential parts are missing; 4 The cassette holder is missing The speaker cover is missing Vacuum cleaner without hose Display cover is missing • It shows physical damage (burned parts, broken pieces, distorted cables) that impairs its functionality or safety; or The appearance is generally worn or damaged, thus reducing the marketability of the item(s); Defect radiator Do not export worn-out tyres Defect pressure washers • There is no regular market for the used item; Be smart! Do not export an item that has a low marketable value. For example: Gas stoves are widely used in Ghana. Therefore, shipping electric stoves to Ghana with its high electricity tariffs may be the same as shipping waste there. In other words, there is no regular market for electric stoves in Ghana. 5 • The item contains a substance that is prohibited by law (e.g. CFCs, halon, PCB, asbestos); Sections 6-7 of the Norwegian Product Regulations prohibit the export of products and equipment that may contain CFCs, halon, tetrachloromethane, HBFCS etc. Do not export fridges, air-conditioners, freezers, cooling boxes, fire extinguishers and anything that might contain or use ozone depleting substances such as CFCs (chlorofluorocarbons) and halons. HOW CAN ONE TELL IF AN ITEM CONTAINS AN OZONE DEPLETING SUBSTANCE? Most fridges and freezers are marked with an «appliance rating plate» - a metal plate or sticky label which is found either on the back or interior of the appliance or on the compressor as shown below. Before 1996, most extinguishing agents, propellants and solvents contained CFCs or halons. R12 for example indicates the presence of CFC. Do not export equipment marked with the following codes: R11, R12, R 13, R 114, R 500, R 502, R 503, FR 10 A. Fridge compressor marked with R12 The fridge is working properly and looks «new» too. But its compressor uses CFC gas. It should not therefore be exported. As a matter of precaution, do not export spare parts of fridges or freezers regardless of whether they contain CFCs or not. NB: Do not export PCB-oil containing transformers (polychlorinated biphenyls). 6 • The item is destined for disposal or recycling instead of re-use; Collected items from the take-back system • The item is old and out-dated Outdated electric sewing-machines Outdated radio Do not export old fridges, TVs, computers, video-recorders, cassette players etc. One must think about RAM, capacity, processor type, speed and other important specifications of a computer before exporting them to traders, family members or institutions in developing countries. Old computers for example, have low memory and are so slow that they are basically useless or waste. Their monitors also contain a lot of toxic substances. Please note that many consumers in developing countries are no longer interested in old or outdated equipment. Many of these old items are simply not marketable. A very good example is the shift from the use of video-recorders to DVD players in some developing countries. Do not export old mobile phones and /or mobile phones with weak batteries (short lifespan). These weak or «waste batteries» are usually improperly disposed of. Batteries contain a range of metals which are harmful to human health and the environment. 7 • Further use of the item is not certain Avoid equipment or parts of equipment destined for dismantling (for spare parts). • The packaging for protecting it from damage during transport, loading and unloading operations is insufficient; Package and pack your goods as if they were new. Insufficient packaging and reckless packing are not acceptable. The following are unacceptable: Do not put 2 or 3 tyres in one tyre 8 USED VEHICLES/END-OF-LIFE VEHICLES AND SPARE PARTS Gone are the days when almost all types of cars regardless of age, condition etc. could be sent out of Europe. Sending waste end-of-life vehicles to developing countries is illegal. General criteria for distinguishing between used vehicles (or car spare parts) and end-of-life vehicles a) the technical state of the vehicle (or car spare parts eg. engines, gearbox etc); b) cost of repair; c) the presence or absence of liquids or hazardous components EXPORT OF USED VEHICLES In order to ship used vehicles from Norway in a legal way, please check the list below: • The vehicle meets the legal requirements to drive on public roads in Norway • The vehicle does not have extensive rust on major parts of the body • The vehicle has all tyres in place • The body of the vehicle is not heavily damaged • The vehicle is not welded together with another vehicle • The vehicle has no leaks • Essential parts of the vehicle are not missing or damaged. Good engine and gearbox • Official vehicle registration certificate and sales contracts/receipts can be provided Leaks Extensively damaged 9 It should be noted that pouring the contents of car engines and car batteries into drains, water bodies and on the ground is illegal in Norway. Extensive rust/ weak body Without tyres EXPORT OF CAR SPARE PARTS Do not export car spare parts containing liquids or other hazardous components. For example, car engines should not contain oil and oil filters should also be removed. Car engine containing oil Do not export car spare parts that are damaged or covered with rust (especially car fenders and doors. Spare parts should be clean and without leaks. Leaks 10 Damaged muffler As you can see, there are very strict regulations governing the export of «used goods» from Norway. In cases of doubt, you should contact SFT. FOR FURTHER INFORMATION, PLEASE VISIT: www.sft.no www.impeltfs.eu www.bipro.de/waste-events/ http://ec.europa.eu/environment/waste/shipments/guidance.htm http://ec.europa.eu/environment/waste/shipments/index.htm http://www.umweltbundesamt.de/abfallwirtschaft-e/gav/index.htm http://www.vrom.nl/docs/IMPEL-TFS.pdf http://www.royalhaskoning.com/Royal_ 11 Norwegian Pollution Control Authority P.O.Box 8100 Dep. NO–0032 Oslo Norway Visiting address: Strømsveien 96 Telephone: +47 22 57 34 00 Telefax: +47 22 67 67 06 E-mail: [email protected] Internet: www.sft.no Printing: GRØSET™ - Production is climateneutral with compensation for CO2 emission
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